Data Processing Addendum
Version 1.1 · Last updated: 2026-11-02
Counsel-ready template — have a licensed attorney finalize before public commercial launch.
1. Parties & roles
Customer is Controller of archive personal data. LifeThread operator is Processor for hosted processing. This DPA supplements the Terms and Privacy Policy.
2. Processing details
- Subject matter: hosting and operating life archives
- Duration: term of the customer agreement + deletion/return period
- Nature: storage, retrieval, search, Ask/Speak, family sharing, billing
- Types of data: identity, biographical, media, relationship, and related archive content entered by Customer users
- Data subjects: Customer account holders and persons described in archives
3. Processor obligations
- Process only on documented Customer instructions
- Ensure confidentiality of authorized persons
- Implement appropriate technical/organizational measures
- Assist with data subject requests where feasible in-product
- Delete or return personal data after end of services (subject to backups)
4. No sale of personal data
Processor does not sell Customer personal data to third parties and does not process archive content for advertising or data-broker purposes. Subprocessors are engaged only as needed to operate the Service (see below).
5. Subprocessors
Processor may use carefully selected subprocessors solely to operate the Service, such as: cloud hosting, managed database, payment processing, email delivery, and (if Customer enables Ask) an optional AI inference provider. A current subprocessor list is available on request via Contact.
6. International transfers & security
Transfers and SCCs, breach notification timelines, and audit rights should be completed by counsel for the Customer’s jurisdiction.